Subject: Nuclear power park to be set up in Jaitapur, in Maharashtra’s Ratnagiri district within WGs

Greetings from the Western Ghats (WGs), which your ministry claims to protect and conserve as one of the important bio-diversity hot spots in the world.

I am amongst those who are deeply concerned with MoEF’s decision to give the green signal to a nuclear power park to be set up in Jaitapur, in Maharashtra’s Ratnagiri district within WGs. A lot of goodwill built by MoEF since you took over seems to have been eroded by this single decision for very obvious reasons. A nuclear power park of this gigantic capacity (nearly 10,000 MW and the biggest anywhere) can never be substantiated at such an environmentally sensitive location. Has MoEF considered the vast additional stretches of WGs which will have to be compromised to build a number of transmission lines to evacuate the 10,000 MW of power to other parts of Maharastra and other states? A power project of this size may need about ten of 765 kV lines or five HVDC lines, which may mean a right of way of about 500 meters wide running for hundreds of kM. The decision can not be supported on technical, economic or social grounds also.

The concerned authorities would do well to clarify to the public as to how the proposed site in a bio-diversity hotspot has become essential to locate the world’s largest nuclear power park? The public would like to know as to how many of the criteria laid down by Department of Atomic Energy (DAE) for a nuclear power plant site have been fully met and which have not been met in this case. I was given to understand that most of these criteria were not fulfilled even in the case of Kaiga Nuclear Power Project, again in WGs of Karnataka. When we look at the fact that another nuclear power project has been cleared by MoEF within WGs (within few hundred kM of each other) despite the stiff opposition to the Kaiga Nuclear Power Project, the very commitment of the govt. to protect our bio-diversity and its sensitivity to the public sentiments can come under serious questioning.

Worse still, it is not at all clear how MoEF can consider that thousands of acres of land in the lush green areas of WGs for this project have suddenly become expendable. Your statement that “I am aware that the Jaitapur power project is coming up in an eco-sensitive area” as reported in Express News Service makes the issue even more complex. Can you please elaborate to the public as to what exigencies existed for MoEF to clear a nuclear power project proposal in an eco-sensitive area? Even if nuclear power is considered essential for the energy security of the country (which is against all reasoning of wisdom), why this particular site for such a ghastly power project? Do we see a clear compromise of MoEF’s mandate in this case to accommodate French govt. supported project?

The press also has attributed to you: “It was not an easy task… It is a balancing act…”. This opt repeated statement about balancing act is seen by the public as a convenient tool for leaders to support environmentally damaging decisions. We have seen that since independence this “balancing act“ has always favored large project proponents and has lead to massive destruction of bio-diversity, so much so that the govt. is now forced to embark on many initiatives to protect the forests and also to increase the forest cover. At a time when Western Ghats Ecology Expert Panel (WGEEP) has been asked to study the WGs to recommend areas to be declared as ecologically sensitive areas, it is presumptuous for MoEF to consider this area as expendable. The recent report by Chairman, WGEEP “Rathnagiri and Sindhudurg districts: Summary draft report of the Maharashtra Government consultation, 30th September & study tour, 4th to 11th October, 2010” has elaborately stated as to how these two districts are ecologically of very high value, and why large projects should be kept away from these districts. In view of this report alone MOEF’s decision on Jaitapura nuclear power project becomes untenable. It is very sad if MoEF ignores a credible report by its own task force. One would have expected MoEF to at least wait for the final report from WGEEP without taking the risk of being seen as compromising the norms to facilitate the signing of the pact during the recent visit of French President.

The much touted 35 conditions and safeguards, which are reported to have been attached to the clearance given, are no guarantee for the safety of people, bio-diversity and environment of the area. At best they are seen as a part of a weak defense against an apparently erroneous decision, because MoEF is generally seen as having no teeth to enforce these conditions on such a high profile project. Since independence there are hardly any projects of such a profile, which have been stopped for the violation of license conditions. No one will accept the feeble argument that once this project gets fully commissioned, it can be stopped for even a very serious violation of any of license conditions. So much money would have been poured into the project by that time and so high its profile would be that it is inconceivable that MoEF can muster courage even to think of stopping its operations.

It is in the background of such compromised decisions that the objectivity of the Green India Mission (GIM) is being increasingly questioned. If we cannot protect the natural vegetation in a bio-diversity hotspot, it is preposterous to think that by spending Rs. 40,000 crores under GIM, we will ensure adequate level of the green cover in the country. It is also unwise to think that the mono cultivation, which is most likely to happen under GIM, can adequately compensate the loss of natural bio-diversity due to such ill-conceived projects.

You are also reported to have stated that your ministry has no jurisdiction over radiology emission. Such a statement would be very sad; for MoEF should have clarified this issue with the concerned ministry. It is tragic that there is no administrative mechanism in our country by which all these issues are considered objectively by a single agency at least in the final stage of approval process, and that many such critical issues are falling through the crack between the so called jurisdictions of different ministries.

As I have been mentioning in many of my earlier communications to you, the Costs & Benefits Analysis (CBA) could have been an effective mechanism for MoEF to question the efficacy of the proposed project in view of the huge issues facing the society. Assuming that MoEF is seriously concerned about the diversion of such a large chunk of bio-diversity rich land for a high impact project, an objective CBA could have given a strong basis to demonstrate to other ministries that the costs to the society are unbearably high as compared to the meager benefits from this project. Unfortunately, CBA is not a part of the mandatory approval process in our country, as it should have been and as practiced in many parts of the world. Even at this stage if MoEF is really concerned about our environment, there is a scope for deploying the CBA effectively to persuade the central govt. to reconsider the project proposal. The civil society can provide the relevant data to be used in such a CBA.

An essential aspect of an objectively considered CBA is to consider various credible options available to meet a given objective. In the present case assuming that generating electricity alone is the objective, a decent understanding of the Indian power sector indicates that there are many benign options available to get an equivalent of 10,000 MW of generating capacity.

Ø Since the nuclear power facilities consume about 10% of generated power in station auxiliary systems, we may not expect more than 9,000 MW export from Jaitapura nuclear power plant at any given time. Assuming that the plant is dedicated for the Western Region alone, 30% of T&D losses prevailing in the region (during 2006-07 as per CEA annual report) will mean that a maximum of about 6,300 MW of this project can be available for end consumers in the business as usual scenario. Because of past experience of an availability factor of 80% for the Indian nuclear power plants, this also corresponds to about 44,000 Million Units of annual energy for the end use.

T&D losses in Western Region alone, if reduced to 15% (as per the National Electricity Policy target of 15% T&D losses by 2012), Western Region can get additionally about 4,800 MW (in Western Region the peak demand met was 32,100 MW in 2009-10 as per CEA website) from the existing facilities itself.

Additionally, even if only 50% of the inefficient incandescent lamps in the Western Region (in the states of Maharastra, Madhya Pradesh, Chattisgarh, Gujarath, and Goa) are replaced by much more efficient CFLs the additional virtual capacity available can be more than 1,500 MW.

From these two simple efficiency improvement measures alone the region can get more than 6,300 MW additional virtual capacity, which is what the net benefit could be from the proposed power plant. These two efficiency improvement benefits can come at a cost which is likely to be less than 25% of the direct financial cost of the proposed nuclear power project. Not a single tree needs to be cut; nor a single family will be displaced; not single ton of GHG emission will be added. On the contrary, the two efficiency improvement measures will lead to reduced total GHG emissions in the country.

Ø At the national level on an average, about 34% of the electricity consumption is for the irrigation pump sets (IP sets), which are reported to be wasting about 50% of that energy due to technical reasons. It is also known that this loss can be reduced to less than 10% by simple technical measures at a small cost. The Western Region, with heavy usage of IP sets in Maharastra and Gujarat, can be assumed to be consuming at least 34% of electricity in IP sets alone.

Electricity consumed in Western Region during 2009-10 was about 223,000 Million Units (as per CEA website) out of which about 76,000 Million Units (34% of the total consumption) can be assumed for IP sets. Out of 38,000 Million Units, which is being lost in technical losses, about 34,000 Million Units can be recovered by efficiency improvement measures. This measure along with a modest efficiency savings from domestic consumption (which itself is about 19% of the total energy consumption, and which has about 30% savings potential as per Prayas Energy Group survey) can easily match the possible energy benefits from the proposed nuclear power plant.

Ø Of the total thermal power capacity of about 37,000 MW in Western Region, if the average PLF is improved from the present level of about 65% is taken to about 80% (as compared to more than 85% in case of NTPC power plants), the resultant improvement can provide about 5,500 MW virtual additional capacity to the existing system. This can come at an additional cost which will be a very small fraction of the capital cost of proposed nuclear power plant.

Many other benign alternatives could be visible if the concerned authorities care to look for them. It is very pertinent to state that the benefits from these alternatives can come at much less overall cost to the society and with least impact on the environment and the population. In this context it is very unfortunate that no ministry/agency in our country is taking such a holistic look to the energy needs of our society. Without considering various alternatives it may be considered as scandalous to consider that a nuclear power park at horrendous cost should be acceptable to the society. MoEF with a clear mandate to protect the forests, bio-diversity and the general environment of the country should raise these issues before giving its final consent.

A statement has also been attributed to you: “ …. We need to change our fuel mix as 35 per cent of our carbon dioxide emissions come from electricity.” A decent understanding of the nuclear power cycle will establish that GHG emission from nuclear power is not inconsiderable when we objectively consider GHG emissions at the stages of mining, processing, transportation of nuclear fuel, and in storage of spent fuel. It is also credible to estimate that during the overall life cycle of nuclear fuels, from the stage of mining till half life of the spent fuel, the energy it consumes is more than that it generates. In view of the fact that about 50 to 60% of the total cost of a nuclear power plant goes to meet the cost of the main plant machinery, the carbon foot print of manufacturing these machines and accessories itself can be huge. Has MoEF considered the inter-generational injustice in the need for safeguarding the spent nuclear fuel for tens of future generations?

You are also reported to have said that: “ …. It is absolutely essential to get an assurance from the Maharashtra government to study the cumulative carrying capacity of the region …. ”. Looking at the past record of how the state governments have shown scant respect for the concept of the cumulative carrying capacity of a region, MoEF should have insisted for such a study before giving its consent for the proposed project. The public cannot accept the weak argument by MoEF that cumulative carrying capacity of the region has to be carried by state govt. We also have seen the reports that even the faulty public hearing held have seen huge opposition to the proposed project.

Considering all these issues it is very sad that MoEF seem to have ignored the credible risks to our society and given a green signal to the project obviously because of the political pressure. In this context the public cannot be faulted for the common view that various initiatives such as Green India Mission are likely to be only a waste of public money.

Since the proposed project has not been fully committed for the financial closure yet, I believe there is still a possibility for MoEF to regain the confidence of the public, and hence request that all the relevant issues be considered objectively, the concerned public be involved in such an exercise, and the best possible solution to meet the legitimate demand for electricity is chosen. Unless the government demonstrates to the public that all the related issues have been considered objectively and transparently to safeguard the interest of our society, the public trust is likely to be eroded seriously, which in turn will not be in the interest of our society. There is also a credible risk that the government’s stand on Global Warming is viewed by the public as just posturing for the international community without any serious commitment to live upto it.